Last Updated: October 2023

This privacy policy (the “Policy”) explains how Aistocks, (hereinafter referred to as “Aistocks,” “we,” or “us“) collects, uses, and discloses personal information through its websites, mobile applications, and other online products and services linked to this Policy, including any of the products and services described in the following paragraph (collectively, the “Services“), or when you otherwise engage with us.

The Services encompass: (i) the Aistocks social trading platform for investing in stocks, and ETFs, for which users can register an account; (ii) Aistocks Digital Assets Exchange Services; (iii) any other website, web platform, or service provided by Aistocks (an “Aistocks Account” for the purposes of this Policy).

We strongly encourage you to carefully read this Policy as it constitutes part of the relevant terms and conditions, business terms, agreements with you, or terms of use established by Aistocks, as applicable.

If you accept or agree to this Policy on behalf of a company or other legal entity, you represent and warrant that you have the authority to bind that company or other legal entity to this Privacy Policy, and, in such an event, “you” and “your” will refer and apply to that company or other legal entity.

Application of this Policy

For the purposes of applicable state and/or international data protection laws, the respective Aistocks entity with which you have registered is the “controller” of personal information collected through aistocks.vip, other Aistocks group entities’ websites, widgets, mobile applications, and other platforms (together the “Site”). It is the company to contact if you have questions about the use of your personal information (see the “Contact Us” section below). The Policy also applies to personal data about each authorized representative of a client and about other persons or entities when this personal data is collected in the course of providing the Services (such as directors of corporate clients).

Collection of Information

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information when you create an Aistocks Account, engage in any interactive features of the Services, complete a form, participate in a contest or promotion, make a purchase, communicate with us via third-party social media sites, request customer support, or otherwise communicate with us.

When You Sign Up or Register for an Aistocks Account or Services

If you sign up for an Aistocks Account or other Services, we will collect basic information about you, including your name, email address, and telephone number. You may provide this information directly to us or by signing in to your account/service with a third party, including but not limited to Facebook or Google (see “Information We Collect from Other Sources” below). We will use the information we collect about you to:

– Create and maintain your Aistocks Account;

– Allow you to log in to Aistocks;

– Contact you about your Aistocks Account and/or our Services (this may include marketing emails).

When You Provide Information to Build Your Profile

Once you have created an Aistocks Account, we will request additional information to enable you to utilize certain functions. We will ask for a copy of an identification document required by us to comply with our regulatory obligations and verify your identity. Further details about the identification process can be found in the relevant Aistocks entity’s terms and conditions, business terms, and/or terms of use or client/customer agreement, as applicable.

Please note that if you choose to provide additional information about yourself to complete your “Profile,” the information we request may include details or questions that may be required during the Profile creation process. This process may be amended by us from time to time.

Providing this information is optional, but for legal and regulatory reasons, you may be unable to use certain features unless you provide further information.

We will use the information you provide in your Profile to:

– Verify your identity and conduct checks required by applicable laws and regulations, including but not limited to “know your customer” (KYC), anti-money laundering, fraud, sanctions, and politically exposed person (PEP) checks;

– Contact you regarding your Aistocks Account, including requesting additional information or documentation;

– Provide you with notices related to your Aistocks Account, general updates, market updates, and other marketing materials, including information about the Services offered by members of the Aistocks Group;

– Tailor the products and services offered through the Site to you, including performing suitability or appropriateness assessments for using our services and/or products;

– Assess your credit risk;

– Assess your risk score according to parameters determined by Aistocks;

– Determine whether you qualify as a professional client, wholesale client, or another specific category of client;

– Maintain administrative records related to our business;

– Set up security measures to secure your account, including carrying out two-factor authentication (“2FA”); and

– Provide the Services.

You can update your Profile at any time by visiting the “Account” page in the Settings menu when logged into your Aistocks Account. We recommend that you regularly update your Profile to ensure that the Aistocks functions offered to you are appropriate for your current circumstances. You also agree to update such information upon Aistocks’ request if Aistocks considers the information provided as untrue, incorrect, incomplete, and/or inconsistent with other information provided by you at any time. You acknowledge that we may rely upon such information, and you are responsible for any damages or losses that may result from any inaccuracies, including the inappropriateness of our Services for your Profile. Completing your Profile is optional, and you are not required to provide this information. However, if you choose not to do so, we may be unable to offer the full functionality of Aistocks to you.

 

When You Contact Us

 

If you contact us by telephone, email, post, or use another function offered by Aistocks, such as the chat feature, we will collect information about the communication and any additional information you choose to provide us. We will use this information to review, investigate, and respond to any comments or questions you may raise. Please note that we record and retain all telephone calls and other communications with us and may use them in our dealings with you, including any dispute resolution or legal proceedings.

When an Aistocks User Invites You to Use Aistocks

Users of Aistocks can invite their contacts to sign up for an account with us. We only collect the email addresses of individuals that users choose to invite to join Aistocks, and Aistocks only uses the email addresses for sending an invitation to the individual at the request of the existing Aistocks user.

Information About Your Use of Aistocks Services

Usage and Automatically Collected Information

When you access or use our Services at Aistocks, we automatically collect information about you (the type of information depends on the Site you are using), including:

• Financial Information: We collect financial information related to your use of the Services at Aistocks, including information you provide to us or that we collect from public sources.
• Log Information: We collect log information about your use of the Services, including the type of browser you use, app version, access times, pages viewed, your IP address, any other network identifiers, and the page you visited before navigating to our Services.
• Device Information: We collect information about the computer or mobile device you use to access our Services at Aistocks, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
• Activities on the Site: We collect records of activities on the Site, including any content you post, your Aistocks Account details, the time, value, and currency of any deposit, withdrawal, or transaction made, and the payment method.
• Location Information: In accordance with your device permissions, we may collect information about the geo-location of your device.
• Information Collected by Cookies and Other Tracking Technologies: We use different technologies to collect information, including cookies and web beacons. You can find out more about Aistocks’ use of cookies and similar technologies in our Cookie Policy.

Information We Collect from Other Sources

We may collect personal information about you from third-party entities when we seek to verify your identity as part of our regulatory requirements. This may include, for example, identity verification agencies, credit referencing agencies, and similar bodies. We may also collect information about you from third parties when you use or connect to Aistocks by or through a third-party platform, such as Facebook or another site. By doing so, you allow us to access and/or collect certain information from your third-party platform profile/account, as permitted by the terms of the agreement and your privacy settings with the third-party platform. We will share such information with the third-party platform for their use.

Some of the information we collect from you on the installation of the mobile app will be shared by us with vendors and other service providers who are engaged by or working with us in connection with operating and analyzing the Services we provide to you.

Unsolicited Information

If you provide us with personal information that we have not requested, then we will endeavor to only retain the information that we are entitled or required to hold because of the products and services we provide. However, if this additional information is surplus to our requirements but is provided to us in a manner where it is combined with information that we are either required or entitled to retain, then you acknowledge that this unsolicited information may be held by us in the same manner as the balance of your personal information.

Use of Information

We use the information we collect to provide, maintain, and improve the Services at Aistocks, such as to administer, verify, and maintain your account, to provide the Services you request, and customize your experience with us. We also use the information we collect to:

• Carry out our obligations owed to you.
• Comply with our regulatory and other legal obligations.
• Monitor/access any content you post.
• Administer transactions, including deposits, chargebacks, and payments.
• Monitor trading activity on Aistocks, including by detecting inconsistencies in payments and trades and looking out for potentially illegal activities.
• Determine whether a payment method is being abused.
• Compile statistical analysis of the pages of our platform and websites.
• Monitor and analyze our business.
• Investigate and manage inquiries, disputes, and legal proceedings and to comply with court orders, mandatory dispute resolution determinations, and mandatory government authority or law enforcement orders or directions.
• Provide information about you and your trading with us to credit reference/reporting agencies.
• Participate in crime prevention, legal and regulatory compliance, and to assist regulatory, cybercrime, data, and information protection agencies and police with their inquiries and enforcement, even if not compelled to do so.
• Develop and to market other products and services.
• Novate, transfer, or assign any of the rights or liabilities of the Aistocks Entity.

 

Sharing of Information

We will not share the personal information we hold about you except in the following circumstances:

• Between and among the Aistocks Entity, Aistocks, and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership.
• With professional advisors, vendors, consultants, and other service providers, such as payment service providers, IT hosting companies, banks, other financial institutions, and credit reporting/reference agencies who need access to such information to carry out work on our behalf.
• In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of Aistocks by another company.
• Disclosure in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
• If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property, and safety of Aistocks or others.

Social Sharing Features

If you have elected to use one of our applications provided via social networks (such as Facebook, Twitter, etc.), our application will be granted access to your social network account general information. This includes your name and username in the social network, profile picture, gender, networks, user ID, list of friends, and any other information you have permitted to be shared depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services and serve advertisements about our products and services on our behalf across the web and in mobile applications. This may involve cookies and other technologies to collect information about your use of the Services at Aistocks. This information may be used by Aistocks to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services, and better understand your online activity in connection with the Services. Please refer to our Cookie Policy for more information about the cookies involved and the process of consenting or refusing cookies.

Your Choices and Rights

You may have certain rights and protections under the law regarding the processing of your personal data. For example, you may also have the right to object to, or request that we restrict, certain processing and, in some circumstances, to obtain a copy of the personal information in machine-readable format. There are limits to such rights where they apply, and in certain circumstances, we may not be required or able to meet your request, or we may only meet your request in part.

Legal Basis for Processing: For transparency purposes (where relevant under data protection legislation applicable to our processing of your personal information), we process your personal data on the following legal grounds:

• Entering into and Performing the Contract with You: If you have an Aistocks Account or have registered on the Site or for the Services, our legal basis for processing your personal information is that it is necessary for the performance of the relevant Aistocks Entity’s terms and conditions, terms of business, and/or terms of use, and to provide the requested service to you. With respect to an Aistocks Account, this includes facilitating access to our platform, processing payments, and executing trades.
• For other Justifiable Grounds, including Legal Obligation and Legitimate Interests: We process your personal information where necessary for Aistocks to comply with legal and regulatory obligations we are under and also where it is necessary for legitimate interests we have in conducting our business (or the legitimate interests of our partners in complying with their legal obligations), balanced against the rights of our customers, like you. These include without limitation:
• Learning about your interests and preferences to contact you with information that is relevant to you and helping us target marketing communications and advertisements for our products and services so that they are more relevant to you.
• Using your pseudonymized details to show you advertising for our products and services on social media platforms, such as Facebook or via other third-party advertising that may appear on other websites you use. The information shared with these platforms is pseudonymized to protect your personal data.
• Analyzing and continually improving the Site and the Services and helping us pilot test versions of the Site internally to develop new features and ensure the efficient running of Aistocks’ services.
• Detecting and reducing fraud and credit risk.

Data Subject Requests: You may have the right to access personal data we hold about you and to ask that your personal data be updated, corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you can log into your account or contact us via this Link. Alternatively, you may also reach us by email at info@phaionn.com. If you wish to delete or deactivate your account, please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Questions or Complaints: If you are interested in exercising any of these rights (or confirming if they apply to our processing of your personal data), you can log into your account or contact us. Any such request should be submitted in writing to: info@phaionn.com. If you have a concern about our processing of personal data that we are not able to resolve, you may have the right to lodge a complaint with the relevant data protection supervisory authority where you reside. As noted above, even where such rights apply, they are subject to limits. This means that, in certain circumstances, we may not be required or able to meet your request, or we may only meet your request in part.

 

Promotional Communications

You may opt out of receiving promotional emails or text messages from Aistocks by following the instructions in those emails or text messages or by visiting the “Notifications” tab in the “Settings” menu on our platform. If you opt out, we may still send you non-promotional emails, such as service messages about your Aistocks Account or our ongoing business relationship.

Mobile Push Notifications/Alerts

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Aistocks Social Trading Platform

Aistocks provides a real-time social trading platform which integrates rich community and social characteristics into the trading platform. As part of the Aistocks traders’ network, traders who choose to be part of the community share their strategies and performance with the community. The amount traded is never publicly disclosed, and all these traders have expressly agreed to be part of the network and share their strategies and performance.

Downloading, installing, and accessing the Aistocks Services in relation to the trading platform constitutes your agreement and acknowledgment that the following information and content shall be considered non-confidential and non-proprietary information (other than your personal data as described below), collectively, the “Content” and shall be publicly shown on the Site: aistocks.vip.

You can change your privacy settings at any time and can make your trading activity private by clicking here: aistocks.vip.

Retention of Personal Information

We store the information we collect on you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations. The period for which we will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation. For example, if you are invited to use Aistocks by another user, we will store the personal information about you provided by such other user for a period of six months in order to send an invitation to you by email.

If you have an Aistocks Account, we will store your personal information for as long as you maintain that account, and after you cease holding an account, for as long as we are required to by laws and regulations that are applicable to us.

Security and Integrity of Information

We protect your personal information by using data security technology and using tools such as firewalls and data encryption. We also require that you use a personal username and password every time you access your account online. As set out in the relevant Aistocks Entity’s terms and conditions, terms of business, and/or terms of use, you must not share your password with anyone else. We recommend that you do not re-use a password previously used by you for other platforms/services. We strongly encourage you to activate Two Factor Authentication (“2FA”) in your account. 2FA requires you to enter a verification code sent to your mobile phone via SMS in order to access your account.

We restrict access to personal information at our offices so that only officers and/or employees with a legitimate business purpose can access it.

Minors

Aistocks is not available for users under the age of 18 (or the age of legal consent for the jurisdiction the user is located in) (a “Minor”). We do not knowingly collect personal information from or about Minors. If you are a Minor, you should not download or use any of our services nor provide any personal information to us.

If we become aware that a Minor has shared any information with us, we will delete such information. If you have any reason to believe that a Minor has shared any information with us, please contact us at info@phaionn.com.

Changes to this Privacy Policy

The Aistocks Privacy Policy is subject to periodic review and updates to accommodate changes in our operations, practices, and to ensure its ongoing relevance in response to evolving laws, technology, and the business environment. Any personal information held by Aistocks will be governed by our most current Privacy Policy. We encourage you to revisit the Privacy Policy regularly for updates.

Links

Our website may contain links to other websites on the internet. Please be aware that we are not responsible for the content or privacy practices of these external websites. We recommend reviewing the terms of use and privacy statements of such websites when you visit them. Our terms of use and Privacy Policy exclusively pertain to information collected by Aistocks in accordance with this Policy.

Contact Us

If you have inquiries or concerns about the Privacy Policy, we encourage you to get in touch with our customer support by opening a ticket via this link info@phaionn.com. To assist us in addressing your query effectively, kindly provide your full name and email address. In some cases, we may request additional information to verify your identity before facilitating certain rights outlined in this Policy.